PISC Comment on Fostering Innovation and Investment in Wireless Communications Market

On behalf of the Public Interest Spectrum Coalition, we are pleased to submit these reply comments regarding the Commission’s Notice of Inquiry on Fostering Innovation and Investment in the Wireless Communications Market. As the Commission noted, the market for wireless broadband services has been evolving at an extraordinarily rapid pace and is delivering new and empowering technologies to American consumers. Most recently, this is reflected in an exploding consumer demand for mobile data with the increasing use and availability of smartphones and aircard modems. The result of this data explosion has been a near unanimous call from wireless industry operators for more spectrum to meet demand. However, we believe that it is impractical, inefficient and ultimately anti-consumer to attempt to meet the growing demand for mobile data consumption primarily through traditional reallocations of exclusively-licensed spectrum by auction.

Wise policy choices will be necessary to facilitate – and not impede – a market evolution toward these more spectrum-efficient and cost-effective “hybrid” or “heterogeneous” wireless broadband networks. To facilitate this wireless infrastructure, we believe it is essential for the Commission, the executive branch and Congress to explicitly support alternative models for spectrum access through:

• Opportunistic Access to Bands that Cannot be Cleared Quickly
• Wholesale Access: allocation conditioned on leasing bandwidth or transmission to any ISP or application/service will promote market entry, roaming, competition and innovation.
• New Unlicensed Bands: substantial share of newly-cleared spectrum be reallocated for unlicensed use on a national basis.
• Test-Beds to Spur Innovation: Opening additional FCC-held (and NTIA-held) bands could be implemented in tandem with the sort of expanded opportunistic access to a multiplicity of bands that could be managed through the TV Bands Database.

The full comment can be downloaded as a PDF on the right.